Joint Trades Letter to the Board on the Interchange Transaction Fees Survey

Dear Ms. Misback:

The undersigned trade associations (the "Associations") write with respect to the Board of Governors of the Federal Reserve System’s (“Board”) request for comment on its proposal to extend for three years, without revision, the Interchange Transaction Fees Survey (FR 3064).

The Associations respectfully write to reiterate our long-standing concerns about the limitations of the Board's Debit Card Issuer Survey (FR 3064a; referred to herein as the "Issuer Survey"). The information gathered from the Issuer Survey and the Board's use of the limited information provided therein has a significant adverse impact on the debit card marketplace by painting an incomplete picture of the costs incurred by issuers with respect to debit card transactions. The impact and conclusions drawn from this limited information would be more significant and direct if the Board were to finalize as proposed the 2023 amendments to Regulation II ("2023 Proposed Rule"), which the Associations strenuously oppose. The 2023 Proposed Rule would automatically update the interchange fee cap every other year going forward by directly linking the interchange fee cap to the limited data from the Issuer Survey. It is critical that Board policy be informed by robust, accurate, and complete data.

As discussed further herein, while the Associations acknowledge the practical utility of the Issuer Survey, there are opportunities to enhance the Issuer Survey to more accurately capture the current, comprehensive costs incurred by debit card issuers to better inform Board policymaking. Specifically, the Board should amend the Issuer Survey in several key areas to ensure that it captures the full range of costs incurred by issuers with respect to electronic debit card transactions, while balancing the burden on those required to complete the Issuer Survey. These amendments would help to ensure that the Issuer Survey more accurately reflects the current state and features of the debit card marketplace, which would enhance the value of the survey responses to the Board and to other stakeholders.

Download the joint comment letter to read the full text.